Some businesses require credit- or marketing-related data from credit bureaus or other third party credit reporting agencies (CRA), and data providers, in a transactional manner. These enterprises have individual applicants or customers for which credit checks are required, and submit requests for individual credit reports for each customer as needed in the course of their businesses. An example of this kind of business is automobile retailing in which sales personnel perform an online pre-screen on a potential purchaser to determine the individual's ability to purchase an automobile, the class of automobile they can afford to buy, etc. In other businesses, the request for credit or consumer data is carried out on a large scale or ‘batch’ basis rather than individually. Applications are accumulated, and are then sent in batches to a credit bureau for processing. In some marketing activities such as sales and credit solicitations, large-scale data queries are performed by the data provider on behalf of the requesting companies prior to carrying out such marketing to identify applicants with the desired characteristics so that the number of applicants produced from such marketing campaign will be worthwhile in relation to the costs of generating those applicants. An example of businesses engaged in large scale solicitations of this nature are credit card companies that send mass communications or mailings to prospective applicants and then select among applicants those to which to offer credit.
Pre-screens, as opposed to obtaining full credit reports, of prospective customers and applicants are performed by these businesses because applicable laws such as the Fair Credit Report Act (FCRA) define certain requirements for such solicitations, and the manner in which consumer credit data can be used under the FCRA. In any situation lacking an application for a benefit sought by permission of the consumer evidencing the consumer's consent, the FCRA prohibits access to an individual's credit or consumer report. For credit marketing purposes, the FCRA allows the credit file to be used in making business decisions regarding the consumer, but the FCRA prohibits the business from accessing the consumer's credit file directly, without the consumer's explicit permission. Thus pre-screening of candidates using a credit bureau or other CRA or data provider is an important step in the process of evaluating the pool of potential applicants that may receive applications for a benefit such as a credit card, etc. in a marketing campaign. Similar consumer protection and privacy laws in countries other than the United States of America restrict access to consumer credit information.
For large pre-screen activities, businesses generally make requests that are provided manually to the bureau, CRA, or data provider, and the bureau's own staff is required to program the attributes to define the data inquiry. This takes both time and resources for the bureau, CRA or data provider, and results in added cost and delays for the company desiring the data. In addition, if pre-screened data inquiries are made of multiple data bureaus, the need for each bureau's staff to program the attributes results in attributes that are not consistent from one data provider to another.
Additionally, when these attributes are programmed at the credit bureau, the requesting company encounters difficulty in duplicating the same attributes for their own use, in their internal system, when making the determining decision for respondents to the solicitation campaign. This provides adverse consequences to businesses, because they are required under FCRA to apply the same criteria used in solicitation as they use in accepting applicants. Inability to match the attributes used to generate a pool of applicants with the attributes used to accept applicants under an offer can result in violation of the FCRA and other laws.
In addition, by requiring the requesting company to rely on the credit bureau's, CRA's or data provider's internal IT staff, much of the desired control and capacity to react quickly to changes in business environment is removed from the company making the request. This manual effort is a significant barrier to the flexibility and speed with which these types of data inquiries should be pulled in order to respond to market conditions. Consequently, significant resources are presently wasted because of a lack of automation to permit interaction and coordination between the involved individuals, the enterprise platforms, and bureau's, CRA's and data provider's computer systems.
Every pre-screen request for large data inquiries and batch processes used for marketing and solicitation involves complex communication between the requesting company and the credit bureau, CRA or data provider. There is a request, development, and approval process that must be followed for each request for data. In addition, as mentioned, these companies must also use the same attributes used for the pre-screen in the approval process once the solicited applicant applies. Not only is this necessary from a business point of view, it is also required under the FCRA and other consumer regulations. Some companies make these large data requests on a weekly basis, requiring complex tracking of the different attributes being requested, and the results and performance of the data, based upon the attributes used. This process often results in confusion, and in the end, the abandonment of tracking the inquiry performance against the attributes used to initiate the data inquiry. Thus, information that could be useful to the company in conducting its business, or even required by law, is lost. It would be desirable to provide a system that could overcome this problem with previous technologies.
There is a need in some industries to perform a pre-screen of an individual on a transactional basis. A good example is in the automobile retailing industry, as previously mentioned. Currently when a customer arrives at the sales floor at an automobile dealership, in many cases they are asked to fill out a pre-sales application. One aspect of this application is that the customer gives the dealership permission to access and pull their credit report. The dealership uses this credit report as a pre-screening tool to identify the capability of the customer to buy, and the line of vehicles their sales person should be discussing with the customer. This activity is fraught with issues, first and foremost being that there is a high risk that the sales person may not have permissible purpose to access the customer's credit report under the FCRA. This industry, and others like it, requires the ability to prescreen an individual on a transactional basis, and get the results of a pre-screen without pulling the actual FCRA regulated data from the credit and data bureau which raises FCRA compliance issues.
There is also a need to track attributes and report performance of solicitations requiring that the same attributes be used for pre-screening, accepting applications, and evaluating performance of applicants accepted for a benefit or product offering of a business. This is difficult for a business to accomplish if the attributes and rules used in the pre-screening, acceptance, and evaluation process have evolved, as they often do. In addition, the meaning of attributes may vary among credit bureaus, CRAs and other data providers, further obfuscating performance of pre-screen, acceptance, and profitability analyses.
In cases where a decision needs to be made regarding the acceptance of risk or the granting of credit, there are the ongoing issues regarding a copy of an individual's credit data being sent from the safety of a credit bureau, CRA, or data provider's database. Recent events in the credit industry have occurred where a consumer's personal data was sent to fraudsters and other companies for purposes other than FCRA-approved uses. There is therefore a need in the art to provide the capability to better protect consumer's data to the benefit of the business, data provider, and especially the consumer.
Credit grantors have a need for a system in which they can develop and manage their own score cards and attributes, yet conduct the data acquisition and scoring process within the safe confines of a credit bureau's facility. Furthermore, they need a method in which they can develop and test their attribute and scorecard designs on their own desktop system. In addition, credit grantors need a system in which they can have a credit application scored, yet avoid access to the consumer's credit data which may be subject to severe restrictions or prohibited under applicable law.
It would be desirable to provide a system, apparatuses, articles and methods with the capability to overcome the above-identified problems in the prior art.